Interpleader Protects All Claimants Against Life Policy and the Insurer
Who’s on First to Get Life Insurance Proceeds
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Interpleader Protects All Claimants Against Life Policy and the Insurer
In Metropolitan Life Insurance Company v. Selena Sanchez, et al, No. 2:24-cv-03278-TLN-CSK, United States District Court, E.D. California (September 3, 2025) the USDC applied interpleader law.
Case Overview
This case involves an interpleader action brought by the Metropolitan Life Insurance Company (Plaintiff-in-Interpleader) against Selena Sanchez and other defendants (Defendants-in-Interpleader).
Key Points
Plaintiff-in-Interpleader’s Application:
The Plaintiff-in-Interpleader filed an amended application for leave to deposit funds into the Court registry. This application was granted by the Court.
Funds Deposit:
The Plaintiff-in-Interpleader is required to deposit a check payable to the Clerk of the United States District Court for the Eastern District of California in the amount of $10,159.99 plus any applicable interest into an interest-bearing account in the Court Registry.
Purpose of Interpleader:
The interpleader action aims to resolve the issue of multiple claims to the remaining life insurance benefits of the Decedent, Neal Sanchez. The Plaintiff-in-Interpleader seeks to deposit the funds to relieve itself from responsibility while the Court determines the rightful beneficiaries.
Beneficiary Designations:
There is an unresolved issue regarding whether the Decedent intended to change his beneficiary designations for his life insurance benefits due to technical malfunctions in the benefits system. This has led to uncertainty about the distribution of the remaining Plan benefits.
Legal Analysis
The Plaintiff-in-Interpleader seeks to deposit the funds to relieve itself from responsibility while the Court determines the rightful beneficiaries. The interpleader action is brought pursuant to Federal Rule of Civil Procedure 22 and 28 U.S.C. § 1335, which permit a party to file an interpleader claim when the party faces possible exposure to multiple liabilities from the defendants. The core purpose of Rule 67 is to relieve a party who holds a contested fund from responsibility for disbursement of that fund among those claiming some entitlement thereto. The decision to allow the deposit of property pursuant to Rule 67 is discretionary.
Beneficiary Designations
There is a significant issue regarding the Decedent’s beneficiary designations. The Decedent’s beneficiary designation form for the Plan dated March 5, 2014, designates four Defendants-in-Interpleader as equal beneficiaries of 25% each. However, due to a technical error in the benefits system, it is unknown if the Decedent intended to make the same beneficiary designation changes to his life insurance as his 401(k). This has led to the Plaintiff-in-Interpleader being unable to determine the rightful beneficiaries without risking exposure to multiple claims and liabilities.
Court’s Findings
The Court found that the deposit of the remaining life insurance benefits into an interest-bearing account is appropriate and granted the Plaintiff-in-Interpleader’s amended application. This decision was based on the unresolved issue regarding whether the Decedent intended to change his beneficiary designations for his life insurance benefits due to technical malfunctions in the benefits system. This has led to uncertainty about the distribution of the remaining Plan benefits. This action protects the Plaintiff-in-Interpleader from potential liability and ensures that the funds are distributed according to the Court’s determination.
ZALMA OPINION
When multiple parties claim the benefits of a life insurance policy and litigate against the insurer federal rules allow the insurer to deposit the proceeds of the life insurance policy into an interest bearing account under the control of the court and protects the interests of all the claimants and the insurer and gives the court time to determine which beneficiary and how much each are entitled to receive.
(c) 2025 Barry Zalma & ClaimSchool, Inc.
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A Claim by Any Other Name is not a Claim
Post 5182
It is Imperative that Insured Report Potential Claim to Insurers
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In Jeffrey B. Scott v. Certain Underwriters At Lloyd’s, London, Subscribing To Policy No. B0901li1837279, RLI Insurance Company, Certain Underwriters At Lloyds, London And The Insurance Company, Subscribing To Policy No. B0180fn2102430, No. 24-12441, United States Court of Appeals, Eleventh Circuit (August 25, 2025) the court explained the need for a claim to obtain coverage.
Case Background:
This appeal arises from a coverage dispute under a Directors & Officers (D&O) insurance policy. Jeffrey B. Scott, the plaintiff-appellant, was terminated from his role as CEO, President, and Secretary of Gemini Financial Holdings, LLC in October 2019. Following his termination, Scott threatened legal action against Gemini, and ...
A Claim by Any Other Name is not a Claim
Post 5182
It is Imperative that Insured Report Potential Claim to Insurers
Read the full article at https://lnkd.in/gfbwAsxw, See the full video at https://lnkd.in/gea_hgB3 and at https://lnkd.in/ghZ7gjxy, and at https://zalma.com/blog plus more than 5150 posts.
In Jeffrey B. Scott v. Certain Underwriters At Lloyd’s, London, Subscribing To Policy No. B0901li1837279, RLI Insurance Company, Certain Underwriters At Lloyds, London And The Insurance Company, Subscribing To Policy No. B0180fn2102430, No. 24-12441, United States Court of Appeals, Eleventh Circuit (August 25, 2025) the court explained the need for a claim to obtain coverage.
Case Background:
This appeal arises from a coverage dispute under a Directors & Officers (D&O) insurance policy. Jeffrey B. Scott, the plaintiff-appellant, was terminated from his role as CEO, President, and Secretary of Gemini Financial Holdings, LLC in October 2019. Following his termination, Scott threatened legal action against Gemini, and ...
ZIFL Volume 29, Issue 17
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
Posted on September 2, 2025 by Barry Zalma
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Zalma’s Insurance Fraud Letter (ZIFL) continues its 29th year of publication dedicated to those involved in reducing the effect of insurance fraud. ZIFL is published 24 times a year by ClaimSchool and is written by Barry Zalma. It is provided FREE to anyone who visits the site at ZIFL Volume 29, Issue 17
THE SOURCE FOR THE INSURANCE FRAUD PROFESSIONAL
The Contents of the September 1, 2025 Issue of ZIFL Includes
Misrepresentation Claim Requires Production of Representation
Not...
Barry Zalma: Insurance Claims Expert Witness
Posted on September 3, 2025 by Barry Zalma
The Need for a Claims Handling Expert to Defend or Prove a Tort of Bad Faith Suit
© 2025 Barry Zalma, Esq., CFE
When I finished my three year enlistment in the US Army as a Special Agent of US Army Intelligence in 1967, I sought employment where I could use the investigative skills I learned in the Army. After some searching I was hired as a claims trainee by the Fireman’s Fund American Insurance Company. For five years, while attending law school at night while working full time as an insurance adjuster I became familiar with every aspect of the commercial insurance industry.
On January 2, 1972 I was admitted to the California Bar. I practiced law, specializing in insurance claims, insurance coverage and defense of claims against people insured and defense of insurance companies sued for breach of contract and breach of the implied covenant of good faith and fair dealing. After 45 years as an active lawyer, I asked that my license to practice law be declared inactive ...
The Need for a Claims Handling Expert to Defend or Prove a Tort of Bad Faith Suit
© 2025 Barry Zalma, Esq., CFE
When I finished my three year enlistment in the US Army as a Special Agent of US Army Intelligence in 1967, I sought employment where I could use the investigative skills I learned in the Army. After some searching I was hired as a claims trainee by the Fireman’s Fund American Insurance Company. For five years, while attending law school at night while working full time as an insurance adjuster I became familiar with every aspect of the commercial insurance industry.
On January 2, 1972 I was admitted to the California Bar. I practiced law, specializing in insurance claims, insurance coverage and defense of claims against people insured and defense of insurance companies sued for breach of contract and breach of the implied covenant of good faith and fair dealing. After 45 years as an active lawyer, I asked that my license to practice law be declared inactive and became a consultant and expert witness for lawyers representing insurers and lawyers ...
APPRAISAL AWARD SETS AMOUNT OF DAMAGES RECOVERED FROM INSURER
Post 5180
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It’s a Waste of Time to Sue Your Insurer if You Don’t Have Evidence
Evidence Required to Prove Breach of Contract
Read the full article at https://www.linkedin.com/pulse/evidence-required-prove-breach-contract-barry-zalma-esq-cfe-rfelc, see the full video at https://rumble.com/v6yd2z0-evidence-required-to-prove-breach-of-contract.html and at https://youtu.be/2ywEjs3hZsw, and at https://zalma.com/blog plus more than 5150 posts.
It’s a Waste of Time to Sue Your Insurer if You Don’t Have Evidence
In Debbie Beaty and Jonathan Hayes v. Homeowners Of America Insurance Company, No. 01-23-00844-CV, Court of Appeals of Texas, First District (August 26, 2025) Debbie Beaty and Jonathan Hayes filed a claim under their homeowner’s insurance policy with Homeowners of ...
